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St. Rose Facility

Parent Companies:
Equilon Enterprises LLC dba Shell Oil Products US
EPA Facility ID:
100000088228
Other ID:
70087HLLPT27009
Facility DUNS:
0
Parent Company DUNS:
0

Location:

Address:
11842 River Rd, Lot 2
St. Rose, LA 70087
County:
ST. CHARLES
Lat / Long:
29.952, -90.329 (Get map)
Method:
GPS Code Measurements (Psuedo Range) Precise Positioning Service
Description:
Facility Centroid
Horizonal accuracy:
1 m
Horizontal reference datum:
World Geodetic System of 1984
Source map scale:

Owner/Operator:

Name:
Equilon Enterprises LLC dba SOPUS
Phone:
(504) 465-7417
Address:
P.O. Box 10
Norco, LA 70079 -0010
Foreign Address:

Person responsible for RMP implementation:

Name:
Jody Licatino
Title:
Manager - Process Safety

Emergency contact:

Name:
Norco Site Supervisor
Title:
Norco Site Supervisor
Phone:
(504) 465-6174
24-hour phone:
(504) 465-7342
Ext or PIN:
N/A

Other contacts:

Facility (or company) email:
Facility phone:
(504) 465-6837
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
St. Charles Parish LEPC
Full-Time Equivalent Employees:
24
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
2520-00028-V3
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
March 17, 2017
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

NAPHTHA/LSR
RMP ID:
1000042046
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
4,200,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Environmental Resources Management
Address:
775 N. University Blvd
Suite 280
Mobile, AL 36608
Foreign Address:

Phone:
(251) 380-0046

Latest RMP Submission:

Date:
Nov. 22, 2017
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000034398

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

None

3. Toxics: Alternative release

None

4. Flammables: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in NAPHTHA/LSR)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Blast walls

5. Flammables: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in NAPHTHA/LSR)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Excess flow valve

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

NAPHTHA/LSR, Petroleum Refineries (32411)
Prevention Program ID:
1000036616
Safety Review Date
June 23, 2017, since latest RMP submission
PHA Update Date
Nov. 6, 2017, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
Mitigation Systems
  • Dikes
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Aug. 4, 2017, since latest RMP submission
Training Review Date
Feb. 17, 2017, since latest RMP submission
Maintenance Review Date
March 1, 2017, since latest RMP submission
Maintenance Inspection Date
May 15, 2017, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Aug. 29, 2017
Management of Change Review Date
Sept. 1, 2017
Pre-startup Review Date
May 31, 2017
Compliance Audit Date
July 13, 2015
Compliance Audit Change Completion Date
July 14, 2015
Incident Investigation Date
Sept. 21, 2014
Incident Invest. Change Completion Date
July 22, 2015
Participation Plan Review Date
July 13, 2015
Hot Work Review Date
Dec. 1, 2016
Contractor Safety Review Date
June 1, 2016, since latest RMP submission
Contractor Safety Eval. Date
March 1, 2016, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Yes
Facility Own Response Plan:
No
Specific Facility Response Plan:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
April 13, 2016
Local Response Agency:
Local Response Agency Phone:
(504) 783-5050
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

Executive Summary

LDEQ Agency Interest Number: 3462

EPA Facility ID Number: 1000 0008 8228





FACILITY DESCRIPTION AND REGULATED SUBSTANCES



Equilon Enterprises, LLC dba Shell Oil Products (Equilon) owns and operates a petroleum refinery located in St. Rose. St. Charles Parish, Louisiana (St. Rose Refinery). The refinery was acquired by Shell on August 11, 1995 from St. Rose Refining, Inc., a subsidiary of Enjet, Inc. Process units at the St. Rose Refinery include a crude distillation column, vacuum flasher, steam boiler, storage tanks, a wastewater treatment plant, and various support facilities. The refinery operates under Standard Industrial Classification (SIC) code 2911: Petroleum Refining, and North American Industrial Classification System (NAICS) code 32411: Petroleum refineries. Process units at the refinery include a crude distillation column, vacuum flasher, steam boiler, storage tanks, a wastewater treatment plant, and various support facilities. The refinery converted to an asphalt production facility in December 2012.

The facility has a variety of toxic and flammable substances. However, of the materials at the refinery, one flammable substance meets the physical characteristics of a National Fire Protection Association (NFPA) No. 4 flammable substance. The refinery's LSR/Naphtha Tanks TK-8552 and TK-8553 contain this flammable mixture. Each tank contains butane, isopentane, and pentane in quantities greater than 1% by weight and exceeding 10,000 lbs. A flammable worst-case and alternative-case Offsite Consequence Analysis (OCA) were conducted for this material.

The St. Rose Refinery maintains detailed health, safety, and environmental (HSE) management systems to ensure the safe operation of its facility. As part of this commitment, Shell invests resources in various areas of accident prevention such as:

- Safety in process design;

- Safe operating policies and procedures;

- A comprehensive mechanical integrity program;

- Management o
f process changes;

- Training;

- Incident investigation and auditing; and

- Emergency response.



This summary provides an overview of the risk management activities at the St. Rose Refinery, including:

- A description of the facility and substances regulated by the EPA RMP rule;

- A summary of potential release scenarios and potential off-site consequences;

- An overview of the Accident Prevention Program to prevent accidental chemical releases;

- A five-year history of accidental releases of chemicals regulated by EPA's RMP rule;

- An overview of the emergency response program; and

- Existing and planned improvements to prevent accidental chemical releases.



ACCIDENT PREVENTION PROGRAM - MANAGEMENT SYSTEM - Good



Shell maintains a Health, Safety, Security, and Environmental (HSSE) management system and associated policies, procedures, standing instructions, programs and work practices that are related to the RMP Prevention Program's elements.



These policies, procedures, standing instructions, programs and work practices are measures that are designed to help the site identify planned changes, which vary at any given time, that are designed to further enhance the site's existing safety programs and procedures. The following is a summary of some of these measures:



Employee Participation -



Shell encourages employee participation in all phases of its accident prevention management system. There is a St. Rose Refinery Employee Participation policy that addresses participation requirements of various teams and committees, including Health & Safety Committees, Process Hazards Analysis (PHA) teams, and various safety awareness teams. Participants include employees from Operations, Maintenance, Engineering & Technical Support and Management.



Process Safety Information -



The St. Rose Refinery maintains a variety of technical documents to ensure the safe operation of its processes. The Process Safety Management policy requires operating departme
nts maintain and update Process Safety Information (PSI) applicable to their processes. Chemical-specific information is contained in material safety data sheets (SDS), including properties, exposure hazards, emergency response, and exposure treatment considerations. Other PSI documents include, but are not limited to process drawings, descriptions of safe operating parameters and limits, chemical inventories, basis for process design, safeguarding, protective instrument and equipment construction information. Many of the documents, including SDS are electronically available to all refinery employees and Contractors. The Process Safety Management policy also includes a summary table to assist employees in locating process safety information documents and drawings.



Process Hazards Analysis -

The St. Rose Refinery maintains a comprehensive Process Hazards Analysis (PHA) program to identify and control hazards associated with its processes. These include processes covered under one or a combination of: (1) RMP Program 3, (2) OSHA PSM, and (3) Shell internal criteria. The refinery uses the hazard and operability (HAZOP) PHA methodology to conduct process unit PHAs. PHA team members must include experienced employees with operating, maintenance, and engineering backgrounds who are familiar with the affected process. The PHA team is chartered to identify the safety hazards in the process, evaluate the adequacy of existing safeguards in-place, determine the risk of the event occurring, and recommend additional accident prevention mitigations when the team believes such measures are necessary to reduce event risk. All safety related PHA findings are risk ranked to ensure mitigation measures receive timely attention based on their risk priority. All PHA findings are forwarded to local Management for review and resolution. Safety related mitigations approved by Management begin immediately after Management review, starting with the highest risk scenarios. When a final m
itigation cannot be implemented within a reasonable time (e.g. hardware change scheduled to a unit maintenance turnaround), interim solutions such as administrative controls (i.e. operating and work practice changes) must be implemented to mitigate the risk. PHA mitigations are tracked on a quarterly basis until resolved. Process unit PHA's are revalidated every 5 years for the life of the process. Written PHA reports are also retained for the life of the process.



Operating Procedures -

The St. Rose Refinery operating departments maintain written procedures to address a variety of operating modes such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures provide a reference to experience operators, as well as serve as a training tool for new operators. Each PSM covered operating department must annually certify their procedures as current and accurate. The management of change process is also used to ensure operating procedures are updated as necessary to reflect changes in the process unit. Operating procedures are accessible to all St. Rose Refinery employees either electronically or in hard copy.



Operator Training -





The St. Rose Refinery implements a comprehensive training program for all operating, maintenance, and technical personnel. New operating employees receive classroom training on basic operating principles, computer based training, ELearnings, and the operating procedures of their process. In addition to classroom training, on-the job training is accomplished by working with experienced operating personnel. Along with routine operating practices, the training places a significant emphasis on unit specific safety and health hazards, and emergency operating conditions (including shutdown). Employees involved in operating a process must be qualified to perform the job on that process. Operators must re-qualify on their jo
bs every three (3) years and work a pre-designated number of hours by job to maintain qualification. Competency is assessed through a combination of methods such as written and oral tests, and demonstrating skills in the field. The training program complements the written operating procedures to ensure operating employees are properly qualified for their job. All training is documented and managed by the Shell Norco Training Department.



Contractors -



The Contractor workforce at facilities with the control of Shell/Bitumen must go through a thorough indoctrination and permit training before working in the field. The PTW and JSA process ensure adequate handoff and hazard recognition. Mitigation and safeguards are placed based on hazards.



The St. Rose Refinery routinely uses contractors to supplement its maintenance and technical workforce, particularly during periods of increased maintenance or construction activities. Since contractors may work on or near process equipment, Shell has procedures in place to ensure that contractors have the proper knowledge, skills, and training to perform their work in a safe manner prior to working on-site. Contractor safety programs and performance are primary factors influencing the Contractor selection process. Contractors are routinely monitored by a Contract Coordinator to ensure compliance with regulatory and Shell requirements. Contractor safety performance is also part of St. Rose Refinery weekly safety statistics communications to employees and contractors.





Pre-Startup Safety Review (PSSR)



The St. Rose Refinery conducts a PSSR for any new facility or facility modification that requires a change in process safety information. In addition, major projects and maintenance turnarounds require a PSSR to be completed. The purpose of the PSSR is to ensure that safety features such as P&ID and other process drawings, operating and/or maintenance procedures, training and equipment are up to date and appropriately
prepared for startup prior to placing the equipment in service. This review provides an additional check to ensure construction is in accordance with design specifications, that all supporting systems are operationally ready, and personnel are appropriately trained on the modification.



Mechanical Integrity -



The St. Rose Refinery has well-established practices and procedures to maintain the integrity of pressure vessels, storage tanks, piping systems, relief and vent systems, process controls, pumps, and critical instrument systems. The basic aspects of the mechanical integrity program include (1) training for process maintenance activities, (2) ongoing inspection and testing of process equipment, (3) correction of identified equipment deficiencies as appropriate, and (4) quality assurance in construction, installation and spare parts. Maintenance personnel are trained on the safety and health hazards in their work areas, applicable maintenance procedures, emergency response plans, and applicable safe work practices to help ensure they can perform their job in a safe manner. Inspections and tests are performed to ensure that the process equipment functions as intended and that the equipment is within acceptable limits (e.g. acceptable wall thickness for pressure vessels). If a significant deficiency is identified during an intrusive inspection, the operating department must correct the deficiency before placing the equipment back in service. The appropriate mechanical integrity support group (i.e. Pressure Equipment Integrity, Mechanical, Electrical, or Instrumentation) review equipment use and determine any necessary actions to ensure the safe operation of the equipment.



Safe Work Practices and Work Permits -



The St. Rose Refinery has long-standing safe work practices in place to help ensure worker and process safety. Examples include: (1) the control of entry and exit of support personnel in a process area, (2) equipment lockout and tagout procedure
s to ensure isolation of energy sources for equipment undergoing maintenance, (3) procedures for the safe removal of hazardous materials before opening process piping or equipment, (4) a permit process to control hot work, and (5) a policy and permit process to ensure adequate precautions are in place before entry into a confined space. These safe work practices, along with training of affected personnel, form a system to ensure operations and maintenance activities are performed safely.



Management of Change

The St. Rose Refinery has a comprehensive system to manage changes to its processes. This system requires that changes to equipment hardware, chemicals, operating variables (including critical process operating conditions), procedures, operating staff and any other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to ensure that adequate controls are in place to manage any new hazards and verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, equipment information, and procedures are updated to incorporate these changes. In addition, all personnel affected by a change must be provided the necessary notification and training.



Incident Investigation -



The St. Rose Refinery promptly investigates incidents resulting in, or could have reasonably resulted in fire, explosion, significant toxic gas release, major property damage, environmental loss, or personal injury affecting site personnel or the community. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to refinery management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. Th
e final resolution of each finding or recommendation is documented and the investigation results are reviewed with potentially affected employees and contractors. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during PHA revalidations.



RMP Compliance Audit



The St. Rose Refinery maintains a comprehensive audit program to ensure accident prevention policies and procedures are in place and functioning properly. Compliance audits consist of: (1)

OSHA PSM/EPA RMP compliance audits conducted every three years, (2) external compliance audits by Shell's Corporate Office on a three year cycle, and (3) internal management system audits conducted annually to evaluate the accident prevention system for each unit. Employees ranging from hourly, engineering and technical, and management personnel participate as audit team members in the internal audit process. The audit team(s) develops findings that are forwarded to refinery management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented and audit findings are retained for six (6) years.



Site-Specific Prevention Steps - (Good)



The St. Rose Refinery's accident prevention program manages potential hazards to ensure continued safe operation. These prevention steps help to prevent potential accident scenarios that could be caused by (1) equipment failures and (2) human error. The St. Rose Refinery has various safety features to: (1) detect, (2) contain and control, and (3) mitigate the consequences of a release that include:

1. Release detection

- Process alarms;

- Operator surveillance; and

- Portable hydrocarbon monitoring equipment.

2. Release containment and control

- Relief systems designed to prevent equipment over pressurization (i.e. relief valves and flare);

- Dikes to contain liquid releases;

- Redundant equipment (i.e. back-up firew
ater pump); and

- Control valves to allow isolation of the process.

3. Release Mitigation

- Area firewater monitors;

- Mobile emergency response equipment; and

- Trained emergency response personnel.



RMP FIVE YEAR ACCIDENT HISTORY



No accidental releases of RMP covered substances held above their threshold quantity in a covered process that resulted in death, injuries, or significant property damage on site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage were identified for Shell in the last five years (40 CFR 68.12 and 68.42).





EMERGENCY RESPONSE -



St. Rose is part of the Norco Manufacturing Complex. Shell Bitumen St. Rose has a "First Response" contract with IMTT for initial response for all emergencies. In the event IMTT emergency response team needs additional support and/or support need is determined by Site Team Lead, the Shell Response Team will be activated. Details to activate the Emergency Response Plan for St. Rose is listed in Norco Site Emergency Response Policy E-01-07: "St. Rose employees or contractors can report an emergency incident by calling IMTT - 504-463-4214."



Emergency response is coordinated by the site with the St. Charles Parish Department of Emergency Preparedness (DEP), and the St. Charles Parish Local Emergency Planning Committee (LEPC). This coordination includes periodic committee meetings with or communications to local emergency response officials, local government officials, community members, and industry representatives. Trained and equipped site firefighting, HAZMAT, and medical/rescue teams are available. There is a 24-hour communications capability with DEP officials, as well as area emergency response organizations (i.e. local fire departments, Sheriff's department, State Police, etc.). In addition to established lines of communication with area emergency response organizations, the site is also a member of the St. Charles Parish Industrial
Mutual Aid Association. Periodic emergency drills are held with the LEPC, DEP, Mutual Aid Organization members, and local emergency response organizations. Refresher information that is related to the RMP regulated substances is also made available to local emergency response organizations.



The DEP is responsible for maintaining written plans for the preparedness, mitigation, response and recovery of any natural or technological disaster that may occur in St. Charles Parish. This responsibility includes coordination with neighboring parishes that may be affected by an emergency incident within St. Charles Parish. The DEP is also responsible for coordinating the plans and operations of various emergency response agencies in St. Charles Parish such as fire, police, emergency medical services, public works, volunteers, and other groups that respond to emergencies.



The written emergency response plan covers topics such as responding to a potential release, fire, explosion, or chemical release. Procedures and practices related to the maintenance, inspection, testing, and use of emergency response equipment are also in place. Employees receive training in these procedures as necessary to perform their specific response duties.